ML26036A008

LTP Supplemental Information Request Clarification Call

ML26036A008
Person / Time
Site:	Crystal River  (DPR-072)
Issue date:	01/27/2026
From:	William Allen Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Accelerated Decommissioning Partners, Chesapeake Nuclear Services, Haley & Aldrich, Vermont Yankee
References
Download: ML26036A008 (0)

Text

(10-16-2023)

NRC FORM 699 U.S. NUCLEAR REGULATORY COMMISSION CONVERSATION RECORD Page 1 of 1 NRC Form 699 (10-16-2023)

NAME OF PERSON(S)/TITLE CONTACTED OR IN CONTACT WITH YOU See below.

DATE OF CONTACT 01/27/2026 EMAIL ADDRESS TELEPHONE NUMBER (301) 576-2976 TYPE OF CONVERSATION EMAIL TELEPHONE

INCOMING OUTGOING

ORGANIZATION Accelerated Decommissioning Partners Crystal River Unit 3 (ADP CR3), LLC DOCKET NUMBER(S) 50-302 LICENSE NAME AND NUMBER(S)

Crystal River Unit 3, License No. DPR-72 MAIL CONTROL NUMBER(S)

SUBJECT RSI Clarification Call

SUMMARY

AND ACTION REQUIRED (IF ANY)

NRC

Participants:

Chris Allen, Greg Chapman, Randy Fedors, Adam Schwartzman, Amy Minor and Duane White ADP CR3

Participants:

John Jernigan, Luke Self, Billy Reid, Chuck Burtoff and Marshall Blake Vermont Yankee: Daniel Toegel, Andy Miller and Gerald Wood Chesapeake Nuclear: Stewart Bland Haley & Aldrich: Nadia Glucksberg and Elida Danaher The call commenced at 1:00 P.M. eastern standard time. The draft information requests discussed are provided as Enclosure 1. The information requests were discussed in the order shown except that the environmental information request was discussed at the very end of the meeting due to a scheduling conflict for personnel involved. Specifics details about the various information requests discussed during the meeting are provided in Enclosure 2. Providing some of the requested supplemental information using Kiteworks, ADP CR3's information sharing platform, versus submission on the docket was also discussed.

NRC staff asked if it would be possible for Crystal River to respond to the supplemental information requests by February 27, 2026 if NRC staff issued the supplemental requests by January 30, 2026. Crystal River responded that they would be able to provide the responses by that date. The call subsequently ended at 2:00 P.M.

NAME OF PERSON DOCUMENTING CONVERSATION Chris Allen Digitally signed by WILLIAM ALLEN Date: 2026.02.05 04:38:55 -05'00'

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REQUEST FOR SUPPLEMENTAL INFORMATION REGARDING THE LICENSE TERMINATION PLAN AMENDMENT REQUEST FOR CRYSTAL RIVER UNIT 3 DOCKET NOS. 50-302 By letter dated October 15, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No ML25288A001), as supplemented December 11, 2025 (ADAMS Accession No. ML25345A212), ADP CR3 submitted an amendment request to Facility Operating License No. DPR-72 for CR3. The applicant requested approval of the LTP. The applicant also sought to add License Condition 2.C.21 that establishes the criteria for determining when changes to the LTP require prior NRC approval. The NRC staff has determined that both supplemental information and clarifying information is needed to determine if the application is acceptable for review. The information needs are identified below.

SUPPLEMENTAL INFORMATION REQUESTS Technical Review Regulatory Basis:

The regulations at 10 CFR 50.82(a)(9)(ii)(A) require that power reactor licensees submit a License Termination Plan (LTP) that includes a site characterization.

The regulations at 10 CFR 20.1402 state that a site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a total effective dose equivalent (TEDE) to an average member of the critical group that does not exceed 0.25 millisievert per year (mSv/yr) (25 millirem per year) (mrem/yr),

including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA).

The regulations at 10 CFR 20.1501(a)(2) require licensees to make, or cause to be made, surveys of areas, including the subsurface, thatare reasonable under the circumstances to evaluate (i)

The magnitude and extent of radiation levels; and (ii)

Concentrations or quantities of residual radioactivity; and (iii)

The potential radiological hazards of the radiation levels and residual radioactivity detected.

Sampling Supplemental Information Requests

1. LTP Section 2.11.1.1, CRRB - Crystal River Reactor Building, stated that a total of 13 core samples were collected on the 95-foot elevation of the Reactor Building floor and submitted to GEL for analysis of the full-suite of radiological parameters and that only selected samples were used for averaging and determining fractional abundances. GELs analytical results for the selected samples were provided in LTP Table 2-10. LTP Table 2-10 only

2 provided the results for five samples which is insufficient to derive relative fractions, identify insignificant contributors, and establish surrogate ratios.

Request: Provide the results of all thirteen core samples collected in the Reactor Building (RB) during the characterization survey. Also, describe how the insignificant radionuclides and fractional abundances will be determined/verified at the time of final status survey. This would be a concern for survey units immediately adjacent to areas with differing radionuclides of concern or fractional abundances which may have inadvertently spread contamination into the adjacent survey units during remediation activities.

2. Enclosures 7, CHAR-09 Impacted Open Land Area At-Depth Survey and Sampling, and 8 Historical Site Assessment for Crystal River 3, of the LTP describe two events in 1979 and 1980 in which core flood water was cross-tied to the nitrogen system, contaminating the Nitrogen and Hydrogen Stage Area. Enclosure 8 identifies that the affected nitrogen piping was subsequently abandoned in place. Enclosure 8 also documented a July 2010 release of radioactive water outside the Radiologically Controlled Area. As noted in LTP Section 2.7.4.7, NORB - North of the Reactor Building Survey Units, a contaminated nitrogen line was identified approximately 5 feet below ground surface on the northeast berm outside the Turbine Building. Soil sampling detected Co-60 and Cs-137.

Regarding the events in 1979, 1980 and 2010, Enclosures 7 and 8 do not discuss either remediation efforts or sampling activities. LTP Section 2.7.4.7 identifies that remediation occurred when the contaminated nitrogen line was identified; however, no further details are provided. Enclosure 7 indicates that the maximum subsurface sampling depth is 24 inches.

NUREG-1757, Volume 2, Revision 2, Section 3.6, recommends that the depth of residual radioactivity in surface and subsurface soils be determined based on characterization survey results. In instances involving spills or leaks, where migration of residual radioactivity is possible, subsurface sampling to a depth consistent with the extent of the release provides assurance of adequate characterization.

Request: Provide the following for the contamination incidents identified above:

(a) results for surveys conducted during and after the incidents including information on radionuclides of concern (ROCs) and hard to detect (HTD) radionuclide analysis, and (b) justification for limiting subsurface sampling depths to 24 inches when contaminated pipes are deeper than 24 inches.

DCGL Supplemental Information Requests

3. LTP Table 6-15 presented the derived concentration guideline levels (DCGLs) in dpm/100 cm² for a Qbucket across a range of pipe diameters. Similarly, Table 6-14, BOP Building ALARA Surface Scan DCGLs for Various Pipe Diameters, provides corresponding values for the Balance of Plant (BOP). Section 6.3.5.7, Applying LLBP Scenario for Embedded or Buried Piping included a sample calculation for determining the dpm value for a Qbucket in the BOP based on an initial concentration of 9.6 pCi/g. The volumetric concentration DCGL for the Reactor Building is 9.5 pCi/g as specified in LTP Sections 5.2.6 and 6.3.5.4. This concentration would yield lower DCGL values in dpm/100 cm2 than those reflected in Table 6-13.

Request: Provide the spreadsheet or calculations for the derivation of the piping ALARA DCGLs found in Table 6-15, RB ALARA Pipe Surface Scan DCGLs for Various Pipe Diameters to assist NRC staff in verifying the piping DCGLs.

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4. Pursuant to 40 CFR 192, soils associated with the top 15 cm are considered surface soils while subsurface soils are greater than 15 below the surface. This definition is further supported by the definition of surface soil and the discussion of surveys in appendix G to NUREG-1757, volume 2. Appendix L and table 5.2 of NUREG-1757, volume 2, revision 2 extend the depth down to 30 cm. MARSSIM guidance in NUREG-1575 also defines surface soils to be associated with the top 15 cm.

The NRC/EPA MOU, which was established to facilitate decision-making in the decommissioning of NRC-licensed facilities, provides separate soil trigger values for residential and industrial/commercial exposure scenarios. As noted in table 6-2 of the LTP, Crystal River proposes to consider the industrial/commercial values when determining the ALARA DCGL values used for evaluating compliance.

Section 6.3.2 and Table 6-2 of the Crystal River LTP define ALARA DCGLs as the smallest value when comparing site-specific DCGLs calculated using RESRAD-Onsite, version 7.2, and a resident farmer scenario with the NRC/EPA MOU Industrial/Commercial Soil Concentration values. In the case of surface soil DCGLs, no basis is provided for comparing RESRAD-calculated resident farmer DCGLs with NRC/EPA MOU Industrial/Commercial Soil Concentration values instead of NRC/EPA MOU Residential Soil Concentration values, which are associated with an exposure scenario similar to the resident farmer. In addition, no basis is provided for the use of MOU Soil Concentration values, which are intended to address soil contamination on the surface, with subsurface residential farmer DCGLs calculated using RESRAD-Onsite, version 7.2, and a soil depth down to 1 m (i.e., depths greater than what is considered to be the surface).

Request: Provide the following information:

(a) The basis for using NRC/EPA MOU industrial trigger values as DCGL values for a resident farmer exposure scenario, (b) The basis for using NRC/EPA MOU surface soil trigger values as subsurface soil (0 - 1 m) DCGL values, (c) ADP CR3 Procedure NS-FSS-11, Split/Recount Sample Assessment for Final Status Survey, and (d) Electronic RESRAD-Onsite files used to calculate DCGLs and area factors.

Environmental Review Regulatory Basis:

Pursuant to 10 CFR 51.53(d) and 10 CFR 50.82(a)(9)(ii)(G), the LTP must include a description of any new information or significant environmental change associated with the licensee's proposed termination activities to reflect any new information or significant environmental change associated with the applicant's proposed decommissioning activities.

Environmental Assessment Supplemental Information Request Section 8.1.1 states It should be noted that in July 2024, following review of previous versions of this LTP, along with the submittal of additional information per request, the NRC issued an Environmental Assessment for the License Termination Plan for Crystal River Unit 3 in Citrus County, Florida (EA; [8-7]). Based on the EA, the NRC issued a Finding of No Significant

4 Impact (FONSI) as published in the Federal Register [8-8]. With this finding, the following sections have not been updated and represent the accepted data that supported the FONSI.

However, the Environmental Assessment issued by the NRC staff in July 2024 may not be applicable to this licensing action. For example, information on Federally listed species is updated approximately every thirty days. Therefore, the NRC staff needs to confirm that the findings in the July 2024 Environmental Assessment is still valid.

Request: Provide supplemental information, if necessary, including but not limited to information about project completion dates and dose estimates through those dates, the geographic area of the evaluation for each resource area, and Federally listed species that may occur on the site.

CLARIFICATION INFORMATION REQUESTS

1. Section 5.2.4.2, Specific Structural Material Backgrounds indicated that ambient background for concrete may be determined within the survey unit by shielding the face of the detector or taking a measurement with the detector held in the air pointed away from the concrete surface. Describe what is meant by shielding the face of the detector.

2. Section 2.10.1.6, Gamma Surface Scan states Sodium iodide (NaI) scintillation detectors (e.g., Ludlum Model 44-10 and 43-93) were used for these scans. However, the Ludlum Model 43-93 is an alpha/beta scintillation detector. Confirm the type of detector used for the gamma scans discussed in Section 2.10.1.6.

3. Several sections of the LTP (Section 5.2.11.4, Upper Bound of the Gray Region, Section 5.4, Final Status Survey Data Assessment) reference operational DCGLs. Clarify whether the Operational DCGL is the ALARA DCGL. Additionally, Section 5.4.3.5, Investigation Levels states, For CR3, the main IL is the Operational DCGL that is 75% of the DCGLw.

Elsewhere in the LTP, the IL is 75% of the DCGLw or 75% of the ALARA DCGL. Clarify which DCGL is used as a point of comparison.

4. Section 5.3.1.8, Embedded Piping and Penetrations of the LTP states, HTD ROCs are inferred to the applicable gamma radionuclide concentration to derive a concentration for each ROC for each measurement taken. Clarify whether surrogate ratios are being applied for piping and to which piping these may apply.

5. Section 5.3.1.6, Pavement Covered Areas of the LTP explained that paved surfaces will be incorporated into the larger open land survey units in which they reside. Scanning and sampling of the pavement will be conducted. Clarify where soil samples beneath the pavement will be collected and analyzed.

6. Am-241 and Pu-239 are included in the full suite of radionuclides and are included as ROCs in Table 5-6, Ludlum 43-93 or 43-147 Weighted Efficiency for ROCs for Reactor Building.

However, they have been excluded from Table 5-7, Ludlum 43-93 or 43-147 Weighted Efficiency for ROCs for BOP. Clarify if excluding Am-241 and Pu-239 from Table 5-7 is an oversight and reconcile Tables 5-6 and 5-7 as necessary.

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7. Section 2.13.6 of the LTP provided a description of the ongoing groundwater monitoring program. Please confirm if the program will continue as described or if it has or will be modified in accordance with the needs of the LTP. The response may consider the data quality objectives applied for collection of that data and include information on the interpretation and reporting of the data.

EDITORIAL CHANGE REQUESTS

1. Section 2.11.2, Results of Open Land Surveys indicates the characterization details from CHAR-01 are included in Enclosure 3 of the LTP rather than Enclosure 14.

2. Section 2.11.2, Results of Open Land Surveys indicates the CHAR-09 report is found in 0 of the LTP rather than Enclosure 7.

3. The Figure 3-1 title is General Site Conditions - August 2025 which is inconsistent with the text in Section 3.2, Completed Decommissioning Activities and Tasks. The text in Section 3.2 states that Figure 3-1 shows the general state of decommissioning at CR3 as of February 2025. Please reconcile the figure title with the text.

4. The units in the efficiency column of Table 5-9, NaI Detector Scan Efficiencies and Table 5-10, NaI Detector Static Efficiencies is inconsistent with the information in Enclosure 16.

Please reconcile Tables 5-9 and 5-10 with the text in Enclosure 16.

RSI 1: While discussing the Reactor Building sample information request, Crystal River explained that values for only "ve of thirteen sample were reported because they believed that incorporating the remaining eight values would have unnecessarily biased the activity statistical values high, particularly for C-14. Crystal River also noted that the material from which the other 8 samples came from will be removed during decommissioning and therefore would not be representative of "nal conditions. NRC sta asked if Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) methods would be utilized to update the information reported because this type of information would need to be con"rmed by inspection. Crystal River responded that they planned to update the information during the Final Status Surveys.

RSI 2: During discussions about the underground pipe information request, Crystal River stated that, except for the pipe which ran under the ISFSI, their intention was to remove the underground pipe and survey the soil during the process of removing the pipe. Crystal River also said that they planned to sample as much of the pipe internal surfaces as possible for characterization purposes and that remaining pipes will be capped in response to a question by NRC sta. Crystal River indicated that they would clarify these points in response to the RSIs.

RSI-3: For the Reactor Building Derived Concentration Guideline Levels (DCGLs), Crystal River explained that the dierence between the Balance of Plant initial concentration and the Reactor Building initial concentration was caused by dierent radionuclides of concern in the two calculations as well as round o error. Crystal River indicated that they would provide additional details in their response to the RSIs.

RSI-4: Crystal River explained that they chose this approach attempting to negate the need for NRC interactions with the Environmental Protection Agency (EPA). They also explained that, although the Crystal River site will continue to be an industrial site after license termination, their contract with Duke Energy Florida obligated them to release the site using the more conservative Resident Farmer scenario. NRC sta acknowledged that using EPA DCGLs to evaluate subsurface soils was a novel approach not only because the EPA DCGLs are based upon risk versus dose, but also because the EPA DCGLs are primarily associated with surface soils. Crystal River indicated that they would provide additional details describing this approach in their response to the RSIs. Crystal River also indicated that they would provide electronic versions of the RESRAD "les via Kiteworks if they have not already been provided.

RSI-5: To better understand the supplemental Environmental Report information request, Crystal River asked if NRC sta only wanted con"rmation that the projected completion date and personnel exposures provided in the 2024 Environmental Report had changed. NRC sta responded that the information requests in the RSI

were given as examples. NRC sta stated that Crystal River should evaluate the 2024 environmental report and provide information explaining the dierences between current conditions and the 2024 information. Crystal River also asked if consultation with Fish and Wildlife would be necessary. NRC sta suggested checking to see if the endangered species list had changed since the 2024 Environmental Report was issued.

Only Requests for Clari"cation item number seven was discussed; Crystal River indicated that they had no questions on the other items. NRC sta stated that they were unclear which laboratory analysis protocol would be applied to the groundwater samples between now and the "nal status survey: (i) the historical approach from past annual reports on the Radiological Environmental Monitoring Program, or (ii) the enhanced approach implemented for the six wells sampled in support of previous version of the LTP. Crystal River indicated that they planned to continue the latter approach, i.e., reporting Critical Level and Minimum Detectable Concentration values. NRC sta identi"ed that such information might not be necessary in the future and suggested a data quality objectives exercise might be useful.